On June 12, 2026, U.S. Customs and Border Protection (“CBP”), through a Cargo Systems Messaging Service (CSMS) notice, issued a comprehensive new Forced Labor Enforcement Operational Guidance for importers.
USTR Opens Comment Period on Proposed U.S.-China “Board of Trade”
On June 2, 2026, the Office of the United States Trade Representative (“USTR”) announced a public comment period related to the development of a new government-to-government mechanism, a proposed U.S.-China “Board of Trade,” intended to provide an ongoing channel for managing aspects of bilateral trade between the United States and China.
U.S. Government Files Appeal of CIT Decision Ordering Universal Refunds of IEEPA Tariffs to All Importers
In the latest developments regarding tariffs paid under the International Economic Emergency Powers Act (“IEEPA”), the U.S. Department of Justice (“DOJ”) has formally appealed the U.S. Court of International Trade’s (“CIT”) April 17, 2026, universal injunction ordering refunds to all importers to the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”). The DOJ has
USTR Proposes 301 Tariffs on 60 Countries Following Forced Labor Findings; Requests Comments Before July 7th Hearing
On June 2, 2026, the United States Trade Representative (“USTR”) proposed tariffs under Section 301 of the Trade Act of 1974 (“Section 301”) on imports from 60 countries for their failure to enforce prohibitions related to forced labor. The USTR found that these failures are unreasonable and burden U.S. commerce. The proposed tariffs range from 10% to 12.5%, though they do contain several carveouts.
President Trump Reduces Section 232 Tariffs on Certain Agricultural, Mobile Industrial, and HVAC Equipment
On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning (“HVAC”) equipment under Section 232 of the Trade Expansion Act of 1962 (“Section 232”). In the same proclamation, President Trump also added aluminum lithographic plates and steel racks
DOJ to Appeal CIT Order Requiring IEEPA Duty Refunds for Finally Liquidated Entries
On May 29, 2026, the U.S. Department of Justice (“DOJ”) indicated that it will appeal the U.S. Court of International Trade’s (“CIT”) universal injunction ordering U.S. Customs and Border Protection (“CBP”) to reliquidate final entries (entries more than 90 days past liquidation) and refund duties paid under the International Economic Emergency Powers Act (“IEEPA”) by
CIT Orders Customs to Explain Its Position on Issuing IEEPA Refunds for All Entries Regardless of Liquidation Status
On May 27, 2026, following a closed-door conference in Euro-Notions Florida v. United States (CIT # 25-00595) (“Euro-Notions”), Judge Eaton issued two (2) orders which will require U.S. Customs and Border Protection (“CBP”) to explain the Government’s position on issuing IEEPA refunds for all entries, including those that have liquidated beyond the statutory reliquidation period
The Court of International Trade Rules Section 122 Tariffs Unlawful But Limits Relief to Exclusive Importers
On May 7, 2026, the United States Court of International Trade (“CIT” or “Court”) invalidated Proclamation No. 11012 in The State of Oregon, et al. v. United States, et al. and Burlap and Barrel, Inc., et al. v. United States, et al., holding that the President exceeded his statutory authority in imposing a temporary
CBP Issues Guidance on Technical Corrections to Section 232 Duties for Aluminum, Steel, and Copper Imports
U.S. Customs and Border Protection (“CBP”) has issued new guidance addressing technical corrections to recently imposed Section 232 duties on imports of aluminum, steel and copper. Following a Notice of Technical Corrections issued by the Department of Commerce on April 29, 2026, CBP, on May 6, 2026, released CSMS #68554727 clarifying the application of these
CBP Issues Entry Filing and Reporting Guidance on Section 232 Duties for USMCA‑Qualifying Medium and Heavy‑Duty Vehicles
On May 6, 2026, U.S. Customs and Border Protection (“CBP”) released new guidance via CSMS #68559236 regarding the application of 25% Section 232 duties for Medium and Heavy-Duty Vehicles (“MHDVs”) that qualify for preferential treatment under the United States-Mexico-Canada Agreement (“USMCA”). Pursuant to Presidential Proclamation 10984, the Secretary of Commerce may approve eligible MHDVs to